Wells & Wade, Inc. v. United States. Wells & Wade Fruit Co. v. United States

JONES, Chief Judge.

Each of the plaintiffs is seeking to recover Federal income taxes paid for the period • January 9, 1950, to and including December 31, 1950. Since the legal issues involved are identical and the only factual difference is in the names of the respective plaintiffs, the two cases will be dealt with in a single opinion. The primary question presented here is whether the earnings of the plaintiff corporations for the period January 9, 1950, through December 31, 1950, inured solely to the benefit of a charitable organization and are exempt from Federal income taxation under §…